In order to try to prevent major environmental issues at abandoned or closed factories, Ohio adopted a program known as the “Cessation of Regulated Operations” (CRO). While this program has been around since 1996, there are misconceptions among businesses and developers as to what it means when a property goes through CRO.
Ohio EPA’s
Late last year U.S. EPA enacted the "Hazardous Waste Generator Improvements Rule" which constitutes a major overhaul of the federal hazardous waste regulations (RCRA) that apply to any generator of hazardous waste. The new rule impacts thousands of businesses, including even small generators of hazardous waste. EPA estimates that between 424,100 and 676,900
On February 28, 2016, U.S. EPA publicly announced its priority enforcement areas (EPA National Enforcement Initiatives or NEIs) for the next three years (fiscal years 2017-2019). The announcement provides keen insight into how EPA plans to allocate its enforcement resources in the coming years.
EPA describes the NEIs in the following manner:
"Every three
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When most people think of businesses that handle hazardous waste, they think of manufacturing and other industrial companies. The classic image is the storage of 55 gallon drums marked with placards indicating the contents are hazardous.
In the last two years and unlikely sector has found themselves the focus hazardous waste enforcement and regulatory
Owners of small business form corporations, in part, to insulate themselves from personal liability. A recent trend in Ohio is that the State has become far more aggressive in pursuing owners of small businesses personally in environmental enforcement actions.
A business owner could still be pursued even if the corporate formalities were followed. More and
Federal hazardous waste regulations (RCRA) have long been referred to as management from "cradle to grave." In order meet this management principle, the regulations require detailed paper work and reporting from both small and large businesses.
Failure to maintain the proper paper work can result in significant penalties or even change your regulatory status which will have even